Companies should publish sustainability policies or similar covering their entire supply chain — including third party suppliers — implemented and enforced through high-level leadership that engages with wider industry schemes.

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1. Sustainable palm oil policy or commitment for all its operations?

The company details its commitments in its Sustainability Information Document

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2. Policy or commitment applies to direct and third-party suppliers?

Noble Group does not have independent suppliers, but its policy does apply to its scheme smallholders

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3. High-level position of responsibility for sustainability?

The company states that sustainability is the responsibility of Technical Director and Manager for Compliance and Sustainability

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4. Sustainability report published within last two years?

Noble Plantations Pte Ltd. Published a Sustainability Information Document in October 2017

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5. Member of multiple industry schemes or other external initiatives to improve sustainability in relation to palm oil?

Member of UNGC and is a corporate member of WWF in Hong Kong, but not member of initiatives relating to palm oil

n/a

-

No source

6. Verification report on compliance with POIG Charter, if a POIG member?

Companies should publicly report figures on their total landbank and details of different areas under their management. They should also disclose maps of their management areas and provide details on traceability of their products, both to mill and plantation level.

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8. Total land area managed/controlled for oil palm (ha)?

70,705

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9. Total oil palm planted area (ha)?

16,539.2 - The company also reports a landbank figure of 19,200 ha (including 2,249 ha of scheme smallholders) in its 2017 Sustainability Update

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10. Plasma/scheme smallholders planted area (ha)?

2,249

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11. Unplanted (areas designated for future planting)(ha)?

45,527.1

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12. Conservation set-aside area, including HCV area (ha)?

12,093 - Sum of HCV areas and other conservation areas

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13. Area for infrastructure (ha)?

1,533.78

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14. Number of company owned mills?

1 - Another mill is planned for completion in 2019

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15. Maps or coordinates of company owned mills?

Provide coordinates for one mill owned

n/a

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No source

16. Number and names of supplier mills?

This indicator is disabled as it is not applicable to this company.

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17. Maps of estates/management units?

Concession boundaries have been made available to the RSPO and the company declares these represent 100% of their concession sites, but not all may not be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO

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18. Maps of scheme/plasma smallholders?

Scheme smallholder boundaries have been made available to the RSPO as part of their estate maps according to Noble, but not all may be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO

Tha company states that "PT HIP uses the Identity Preserved (IP) supply chain model, with the mill using FFB sourced exclusively from its own supply base certified by the RSPO." This is the only mill in operation currently

Companies should commit to address deforestation and to set aside areas for conservation. They should report on any activities to manage or restore habitat in their conservation areas, or monitor deforestation in their supply chains. They should also provide evidence of species conservation and biodiversity protection.

The commitment applies to its scheme smallholders. The company does not have independent suppliers

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27. Criteria for defining deforestation?

Noble states it has not replaced primary forest or any HCV area since November 2005, does not replace primary forest, identifies and maintains HCV areas, and does not develop HCS areas

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28. Evidence of monitoring deforestation?

The company states that it has a "Conservation Department responsible for establishing and monitoring conservation areas inside and outside of estate boundaries, to detect encroachment or disturbance by local people or by workers. The department is also responsible for informing local people that they are not allowed to grow crops, clear vegetation, erect buildings, hunt, or disturb conservation areas." However, the extent of area being monitored and/or time-frame is unclear

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29. Commitment to set aside areas for conservation?

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30. Evidence of habitat management and/or habitat restoration?

Restoring damaged conservation reserves and identifying areas to be conserved or re-forested where earlier development had eliminated forest habitat. Installing boundary markers and signboards at conservation reserves and undertaking tree planting. Support habitat restoration at private trans-boundary nature reserve

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31. A landscape-level approach?

The company states that they will implement a landscape approach in 2018.

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32. Commitment to biodiversity conservation?

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33. Commitment to not endanger species of conservation concern, referencing international or national system of species classification?

The company states it "is committed to not endangering species of conservation concern, with reference to international and national system of classification as stated in the executive summary of HCV assessment. Both plant and animal species are classified based upon Government Regulation (PP No. 7/1999), CITES and Red List of IUCN."

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34. Commitment to no hunting or only sustainable hunting of species?

The company states hunting is not permitted in conservation areas and also mentions a commitment to 'No hunting or only sustainable hunting of species' to be 'on track' by 2017 and that a hunting management program for sustainable use is under development

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35. Commitment not to operate within internationally and nationally designated protected areas?

The company states that they do not operate in protected areas and there are no designated protection areas in the company's locations

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36. Evidence of species conservation activities?

Species monitoring, community engagement, integrating local villagers as conservation field assistants, etc

Companies should commit to the High Conservation Value (HCV) and High Carbon Stock (HCS) approaches, and to conduct social and environmental impact assessments (SEIA). They should develop and publish monitoring and management plans, and provide evidence through SEIA, HCV and HCS assessments, typically published in summary form due to the sensitive nature of certain sites.

40. High Conservation Value (HCV) assessments for planting undertaken prior to January 2015, and associated management and monitoring plans?

There is public availability of the following HCV assessments:
PT Pusaka Agro Lestari; PT Henrison Inti Persada

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41. High Conservation Value (HCV) assessments for all estates planted since January 2015?

The company states it in 2016 ACOP that has undertaken new planting and submitted RSPO NPP, but none could be found

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42. High Conservation Value (HCV) management and monitoring plans for all estates planted since January 2015?

The company states it in 2016 ACOP that has undertaken new planting and submitted RSPO NPP, but none could be found

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43. Satisfactory review of all High Conservation Value (HCV) assessments undertaken since January 2015 by the HCV ALS Quality Panel?

The company states it in 2016 ACOP that has undertaken new planting and submitted RSPO NPP, but none could be found

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44. Commitment to the High Carbon Stock (HCS) approach?

The company states ""Noble Plantations is committed to applying the High Carbon Stock (HCS) approach to all of our landholdings, and refraining from developing in any HCS areas" however it also references identifying high carbon stocks as described in RSPO principle and criteria 5 and 7, so unclear if using the HCS Approach

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45. High Carbon Stock (HCS) assessments?

The company states that "An independent carbon stock study, using a methodology approved by the RSPO, has been carried out in July 2014 at both sites" but the documents are not publicly available

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46. Commitment to conduct social and environmental impact assessments (SEIAs)?

Companies should commit to protect peatland and undertake best management practices for soils and peat. They should also have policies on zero burning and to reduce their greenhouse gas (GHG) emissions. Companies should report their GHG emissions, as well as any fires that occurred in or around their estates, along with plans for managing and monitoring fires.

The commitment applies to all scheme smallholders (Noble does not have independent FFB suppliers)

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50. Commitment to best management practices for soils and peat?

The company commits to conservation of soils through its environmental protection guidelines, and refers to letter from the Government stating that there is no indication of peat soil and primary forest in the oil palm plantation area

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51. Landbank or planted area on peat (ha)?

0

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52. Evidence of best management practices for soils and peat?

The company gives evidence of best management practices that are undertaken for soil and refers to letter from the Government stating that there is no indication of peat soil and primary forest in the oil palm plantation area

The commitment applies to all scheme smallholders (Noble does not have independent FFB suppliers)

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55. Evidence of management and monitoring fires?

The company states that it uses "an early warning system to detect the occurrence of fire (land, building and mill)" It describes training procedures, equipment and routine fire patrols with the community and Conservation Department

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56. Details/number of hotspots/fires in company estates?

The company only states "Our risk is low, and there have been no fires both in estate and mill"

Companies should commit to managing water use and water quality, providing evidence through time-bound reduction plans, policies on toxic chemical use and treatment of palm oil mill effluent (POME).

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65. Time-bound commitment to improve water use?

The company states "we are committed to improving both water supply and water quality in our programme" and has target of 1 tonne of water per tonne FFB, however this is not time-bound

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66. Time-bound commitment to improve water quality?

The company only states "we are committed to improving both water supply and water quality in our programme."

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67. Progress towards commitment on water use?

The company reports figures on water use and the target was met. However, water used per tonne of FFB processed increased between 2015 and 2016

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68. Progress towards commitment on water quality?

The company reports figures on water quality , but it is unclear whether water quality is improving

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69. Protection of natural waterways through buffer zones?

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70. Evidence of treating palm oil mill effluent (POME)?

The company states "Palm Oil Mill Effluent (POME) is treated in aerobic and anaerobic ponds, to ensure that Biological Oxygen Demand (BOD) levels are safe before being discharged to the water body. The quality of river water is monitored by taking samples for analysis each month, from both downstream and upstream of the discharge point.
The quality of palm oil mill effluent is monitored by taking samples from a trap pit each month. The Company monitors the quality of effluent waste in every pond."

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71. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

0.5 / 1

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72. No use of paraquat?

The company commits to not use paraquat by 2018 and says it is no longer used

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73. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticide by 2018 and says it has stopped use

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74. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

The company commits to not use Stockholm Convention and Rotterdam Convention chemicals by 2018 and says it has stopped use

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75. Integrated Pest Management (IPM) approach?

Noble only states that is has developed a Pest Management Plan, but details are not given

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76. Chemical usage per ha or list of chemicals used?

The company reports a list of pesticides and fertilisers it currently uses in its operations

Companies should commit to respect human rights, including those of indigenous peoples and local communities, consulted with free, prior and informed consent (FPIC). Companies should respect the rights of workers, report relevant workforce data, and comply with health and safety legislation.

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77. Commitment to human rights, referencing the UN Declaration of Human Rights or UN Guiding Principles on Business and Human Rights?

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78. Commitment to respect legal and customary land tenure rights?

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79. Commitment to respect indigenous and local communities' rights, referencing the UN Declaration on the Rights of Indigenous Peoples or ILO 169?

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80. Commitment to free, prior and informed consent (FPIC)?

n/a

-

No source

81. FPIC commitment applies to independent suppliers?

This indicator is disabled as it is not applicable to this company.

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82. Free, prior and informed consent (FPIC) process?

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83. Process for addressing land conflicts?

The company provides a Resolution of Social Conflicts and Land Disputes SOP in its 2015 ACOP

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84. Commitment to ensure food security for local communities?

The company states that it "endeavours to contribute...to promote the fulfilment of human
rights through improving economic (including to ensure food security for local communities),
environmental and social conditions.."

Companies should become members of credible certification standards and report in accordance with all appropriate categories of membership. The Roundtable on Sustainable Palm Oil (RSPO) requires members registered as growers to submit data relating to certification targets for their estates, scheme smallholders and independent fresh fruit bunch (FFB) suppliers, via an annual communications of progress (ACOP) report.

Companies should report details of any programmes or schemes to support both schemed and independent smallholders, as well as criteria to assess suppliers on compliance with company policies, and in what cases suppliers should be suspended or excluded due to non-compliance.

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111. Programme to support scheme smallholders?

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112. Details of support programme for scheme smallholders?

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113. Number or percentage of scheme smallholders involved in programme?

The company details the number of smallholders and states it involves them all in its programmes

n/a

-

Source

114. Programme to support independent smallholders?

This indicator is disabled as it is not applicable to this company.

n/a

-

Source

115. Details of support programme for independent smallholders?

This indicator is disabled as it is not applicable to this company.

n/a

-

Source

116. Number or percentage of independent smallholders involved in programme?

The company only states it is "to establish and maintain appropriate procedures to evaluate and select major suppliers and contractors, based on our human rights and sustainability policies, and to monitor their performance where appropriate."

Companies should operate in an ethical manner at all levels, providing accessible channels and clear procedures for both employees and external stakeholders to raise any grievance or complaint with the company, as well as allowing for whistleblowing.

The company states that "External stakeholders, especially indigenous people, who wish to submit a complaint or grievance can make contact by telephone, and letter (email/facsimile), or directly meet with the Company representative, as a group or individually. They may fill out a Form of Communication and Consultation that shows the kind of complaint, the date, and how the problem arose, with action taken and recommendation for follow-up"

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125. Details of grievances disclosed?

The company only reports that it received no formal complaints on any violation of the rights of indigenous people and no credible complaints on discrimination in any locations in 2016

Media monitor: Noble Group Ltd

SPOTT gathers reports and stories from global media sources, covering specific company activities related to the assessment indicator categories. ZSL does not assess the validity of these reports.

Research protocols:

Research protocols guide how ZSL conducts SPOTT assessments and allocates scores to ensure a fair and consistent approach, setting the expectations for companies on how they should publish ESG data. The full palm oil indicator framework contains 125 indicators across 10 categories, aligned with corporate reporting initiatives.

Map of concessions: Noble Group Ltd

Explore our interactive mapping tool for a satellite view of deforestation and fires in and around concession sites of companies featured on the SPOTT scorecard. These data can support SPOTT users in conducting further research to verify whether or not company commitments are being implemented on the ground.

Use the map search bar to find specific company concessions or locations. Click the concession sites marked by pins to zoom in for more information, then go to the company pages of featured concessions to view their assessments.

Noble Group makes its one mill location available. Concession boundaries have been made available to the RSPO and the company declares these represent 100% of their concession sites, but not all may not be publicly available due to ongoing legal issues. Maps will become available on GeoRSPO. The concessions are not yet available on the SPOTT map.